Workers cleaning a chemical spill at a manufacturer of plastic thermoformed products had not been trained in proper cleanup procedures or provided proper personal protective equipment, according to an OSHA investigation. OSHA found that workers experienced symptoms of overexposure to an isocyanates chemical used in plastics manufacturing that can cause occupational asthma and other lung problems, as well as irritation of the eyes, nose, throat and skin. Seven serious violations, carrying proposed penalties of $49,000, were cited. OSHA initiated the inspection on Sept. 5, 2014, under the National Emphasis Program for Occupational Exposure to Isocyanates*, after it received a complaint that alleged improper cleanup of a spill of approximately 100 gallons of the chemical diphenylmethane diisocyanate, a type of isocyanate. OSHA cited the company for seven serious violations for lack of a hazardous materials spill response plan and failure to train workers on how to respond to spills. Additionally, required personal protective equipment, such as gloves and respirators, was not provided. Here is a breakdown of the citations:
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:
On or about August 25, 2014, the employer did not develop an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations in conjunction with the response to a 100 gallon release of UTC -A Component, which contains up to 100% 4,4’Diphenylmethane diisocyanate.
Citation I Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(3)(iii): Based on the hazardous substances and/or conditions present, the individual in charge of the res did not implement appropriate emergency operations and did not ensure that the personal protective equipment worn was appropriate for the hazards encountered:
On or about August 25, 2014, the employer did not implement appropriate emergency operations and did not ensure that the personal protective equipment worn was appropriate during emergency response operations to a 100 gallon release of UTC – A Component, which contains up to 100% 4,4’Diphenylmethane diisocyanate.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(3)(iv): Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard, did not wear positivepressure self-contained breathing apparatus until such time that the individual in charge of the incident command system determined through the use of air monitoring that a decreased level of respiratory protection would not result in hazardous exposures to employees:
On or about August 25, 2014, the employer did not ensure that employees exposed to hazardous substances presenting an inhalation hazard wear positive pressure self-contained breathing apparatus until such time that the individual in charge determined through the use of air monitoring that a decreased level of respiratory protection would not result in hazardous exposures to employees during emergency response operations to a 100 gallon release of UTC – A Component, which contains up to 100% 4,4′-Diphenylmethane diisocyanate.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(6)(iii): Employees who participated as hazardous materials technicians, or were expected to participate as hazardous materials technicians, had not received at least 24 hours of training equal to the first responder operations level, and in addition have competency in the areas outlined in 29 CFR 1910.120(q)(6)(iii)(A) through (q)(6)(iii)(I) and/or the employer did not so certify: Note: This SAVEs maybe grouped with 29 CFR 1910.120(q)(6) as appropriate.
On or about August 25, 2014, the employer did not ensure that employees who participated as hazardous materials technicians had received at least 24 hours of training equal to the first responder operations level, and in addition have competency in the areas outlined in 29 CFR 1910.120(q)(6)(iii)(A) through (q)(6)(iii)(I) during emergency response operations to a 100 gallon release ofUTC -A Component, which contains up to 100% 4,4′-Diphenylmethane diisocyanate.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):
On or about September 4, 2014, the employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment for employees working in the Bunk Assembly area with chemicals in their area, including but not limited to, UTC -A Component, which contains up to 100% 4,4′-Diphenylmethane diisocyanate.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.138(a): The employer did not select and require employee(s) to use appropriate hand protection when employees’ hands were exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasion; punctures; chemical bums; thermal bums; and harmful temperature extremes.
On or about September 4, 2014, the employer did not select and require employee(s) to use appropriate hand protection when employees’ hands were exposed to hazards such as those from skin absorption of harmful substances for employees working in the Bunk Assembly area with chemicals in their area, including but not limited to, UTC – A Component, which contains up to 100% 4,4′-Diphenylmethane diisocyanate.
Citation 1 Item 7
Type of Violation: Serious; $7,000
29 CFR 1910.1200(h)(3)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:
On or about September 4, 2014, the employer did not provide employees working in the Bunk Assembly area training on the physical and health hazards of the chemicals in their area, including but not limited to, UTC -A Component, which contains up to 100% 4,4′-Diphenylmethane diisocyanate.
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